Privacy Policy

Privacy Policy

Last Updated: April 8th, 2019

At BMI Telecom Inc. (collectively referred to herein as “we”, “us”, “our”,”Recorn” or “BMI Telecom”), we respect the privacy of our Customers, Authorized Users referred to herein as “Users” and the importance of the information they entrust to us. With this in mind, we provide you this privacy policy (the “Policy”) to help you understand the kinds of information we may gather about you when you access our Web Sites (at http://Recorn.app or https:// Recorn.app) or our Services including Recorn App, and the Recorn API, how we may use and disclose the information, and how you can control, correct and/or update the information. By accessing or using the BMI Telecom Web Sites or Services, you are accepting the policies and practices described in this Policy. Each time you visit or use the Web Site or Services, you agree and expressly consent to our collection, use and disclosure of the information that you provide as described in this Policy.

We currently retain no cookie, registration data or other data for visitors to our Websites except for users that have logged in to use our Services.

Information We Collect

To engage our Services as a User, you must be a Customer which is a registered account holder or authorized by a Customer to use their login information. As a User you may record conversations using our mobile application or web application or using Recorn Voip Platform or upload recorded conversations captured by other means. When you register as a Customer and use the Services we will collect the following information:

WE COLLECT:

Your email address

WHY WE COLLECT IT AND HOW WE USE IT:

To create and support your account and provide you with Services.

To communicate with you, for example, informing you about your account status, security updates and website and mobile application information.

To contact you about features, products, services and other promotions that can enhance your use of the Services, in accordance with your communications preferences.

To enforce compliance with our Terms.

HOW WE RETAIN IT:

We keep your email address until you delete your account by sending an email to support@recorn.app

Your Phone number

WHY WE COLLECT IT AND HOW WE USE IT:

To create and support your account and provide you with Services.

To communicate with you, for example, informing you about your account status, security updates and website and mobile application information.

To contact you about features, products, services and other promotions that can enhance your use of the Services, in accordance with your communications preferences.

To enforce compliance with our Terms.

HOW WE RETAIN IT:

We keep your email address until you delete your account by sending an email to support@recorn.app

All events related to use of the Services including access, record, share, edit and delete events

WHY WE COLLECT IT AND HOW WE USE IT:

Usage data is retained in log files to monitor quality of service and to troubleshoot or respond to customer queries.

HOW WE RETAIN IT

Log files are stored for up to five days and are then deleted

WE COLLECT:

Time, location, and calendar information from Google Calendar, iCal, and other calendar programs for current and following day

WHY WE COLLECT IT AND HOW WE USE IT:

To provide helpful reminders to use the Services in upcoming meetings and to automatically assign a title to a Conversation

HOW WE RETAIN IT

We delete all historical calendar information after event has passed.

WE COLLECT:

Name and email for contacts from your mobile device or Google Contacts or that you enter in the Recorn service when you share a Conversation or create a Group

WHY WE COLLECT IT AND HOW WE USE IT:

To simplify process of sharing data from the Services with others

HOW WE RETAIN IT

We store contact information until deleted by the user by deleting their account, or by sending an email to support@recorn.app

WE COLLECT:

Device information: We assign a unique user identifier (UUID) to each mobile device that accesses the Services. We also collect carrier, language settings, operating system, OEM and device model information.

WHY WE COLLECT IT AND HOW WE USE IT:

We collect mobile device information as permissioned by the operating system. We use the UUID to retain status for users that login to the Services through the mobile application. We use other mobile device information for business intelligence and troubleshooting technical issues.

HOW WE RETAIN IT

We store all device information until the user deletes their account or sends an email requesting that information be deleted to support@recorn.app

WE COLLECT

Web browser information: We assign a unique cookie to your web browser when you login as a user to the Services. We do not assign cookies for visitors who do not login to the service.

WHY WE COLLECT IT AND HOW WE USE IT

We use session cookies to retain login status and state in a particular session when using Recorn via a web browser.

HOW WE RETAIN IT

We retain web cookies for up to two weeks whenever the user logs out of Services.

WE COLLECT:

Audio recordings of phone conversations that you capture and upload using the services.

WHY WE COLLECT IT AND HOW WE USE IT:

To create a transcript of the service using the BMI Telecom proprietary ASR (automatic speech recognition). We process the resultant transcript to derive key phrases and other summary data and assign a speaker if the speaker is enrolled by the user.

We may select segments of raw or partially processed audio and associated transcribed text from multiple recorded conversations from different Users of the Services to be used as training data to automatically train our proprietary artificial intelligence (AI) technology. Only after receiving explicit permission from the Customer we may manually transcribe certain recorded conversations to further enrich our training data.

HOW WE RETAIN IT

We store a copy of the recording, the associated transcript, speaker ID, key phrases and other related metadata until it is deleted by the user who uploaded the recording. If it is deleted by the user no record will be retained by BMI Telecom.

WE COLLECT:

Recordings and certain user data from other Services.

WHY WE COLLECT IT AND HOW WE USE IT:

We process all recorded conversations from third party sources the same way we process recordings directly captured via the Services including use of the data in aggregate for training.

We integrate with third party services to automate capture and/or upload of recorded audio conversations for processing through the Services. We may use stored credentials including API keys, to access these services. We may also support direct login to certain third party services through the Services via OAuth, which means that no user credentials for the third party services are stored.

Certain third party service providers may access the Services using API keys provided by BMI Telecom.

HOW WE RETAIN IT

Recordings uploaded from third party services and associated with a User account are processed and retained using the same guidelines for recordings directly captured or uploaded through the Services. Links to third party services are retained until deleted by the user in settings for the Services.

Use and retention of data from third party services that use the BMI Telecom APIs may be governed by the policies of those third party services.

With Whom We May Share Information We Collect

We use services provided by a number of third parties to process usage and certain device data for business intelligence and troubleshooting purposes. These third parties may use cookies, web beacons, mobile device IDs or other unique identifiers to track your use of the Services. We do not share login or personal information with third party data processors.

Fabric—Crash reporting, user acquisition and retention. More information may be found at: https://fabric.io/terms

Google Analytics—Detailed user event data from website. More information may be found at: https://policies.google.com/privacy

AppsFlyer—Ad effectiveness tracking for mobile advertising. More information may be found at: https://www.appsflyer.com/privacy-policy/

We will not share Personal Information or Customer Data with others except as Customer requests per written instructions or by sending a message through the Website or Services, or as indicated herein, or except when we inform you in advance and give you the opportunity to opt out.

We may also share Personal Information or Customer Data as necessary to comply with legal or regulatory requirements and to respond to lawful requests, court orders and legal process, as well as, to protect and defend the rights, property, or safety of us or third parties, including enforcing contracts or policies, or in connection with investigating and preventing fraud.

Your Choices

Customer provides us with instructions on what to do with Customer Data. A Customer has many choices and control over Customer Data. For example, Customer may provision or deprovision access to the Services, enable or disable third-party integrations, manage access to groups or individuals for content shared through the Services. Since these choices and instructions may result in the access, use, disclosure, modification or deletion of certain or all Customer Data, please review the applicable Platform or Services pages for more information about these choices and instructions. You may delete all of your Customer data by requesting that your account is deleted. We will retain no record of any personal data, usage data or other information.

In addition, the browser you use may provide you with the ability to control cookies or other types of local data storage. Your mobile device may provide you with choices around how and whether location or other data is collected and shared. BMI Telecom does not control these choices, or default settings, which are offered by makers of your browser or mobile device operating system.

EU data subjects are granted rights under the General Data Privacy Regulation (GDPR). We are the Processor of information on behalf of its Customers which act as controllers of the information and as such are responsible for directing BMI Telecom to process such data. EU data subjects that wish to view, edit, delete, transfer, or otherwise restrict our use of their Personal Information should email support@recorn.app, Attn: Privacy Officer.

If you have any questions about your information, our use of this information, or your rights when it comes to any of the foregoing, contact us at support@recorn.app.

Information Collected from Minors

BMI Telecom does not knowingly collect personal information from individuals under the age of of 16. If you are under 16, please do not use our services or provide any information to us through the Services. If we learn we have collected or received personal information from a child under 16 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 16, please contact us at support@recorn.app.

Security

BMI Telecom is committed to protecting your information and we take appropriate commercially reasonable physical, electronic, and other security measures to help safeguard personal information from unauthorized access, alteration, or disclosure. Our security practices include: encrypting many of our services using SSL; and frequent review of information collection, storage and processing practices, including physical security measures, to guard against unauthorized access to systems.

Use of Google Sign-in

We use Google Sign-in to ease the process of signing up for and logging into an Recorn account. Users may optionally allow the Recorn service to access calendars and contacts associated with their Google Accounts. With calendars access, the Recorn mobile application can send users timely reminders to record their upcoming meetings, and automatically name these recordings based on calendar event titles. With contacts access, the Recorn service can simplify how users enter the recipients of shared notes, by allowing users to select from their existing contacts instead of requiring users to type out email addresses.

Privacy Shield

BMI Telecom complies with the EU-U.S. Privacy Shield Framework and Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union and Switzerland to the United States. BMI Telecom has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/.

Enforcement and Privacy Complaints by EU and Swiss Citizens

In compliance with the EU-U.S. and Swiss-U.S. Privacy Shield Principles, BMI Telecom commits to resolve complaints about your privacy and our collection or use of your personal information. Persons located in the European Union and Switzerland who have inquiries or complaints regarding this privacy policy should first contact us at support@recorn.app.

Accountability for Onward Transfer

In the event we transfer personal data covered by the Privacy Shield Framework to a third party acting as a controller, we will do so consistent with any notice provided to data subjects and any consent they have given, and only if the third party has given us contractual assurances that it will (i) process the personal data for limited and specified purposes consistent with any consent provided by the Data Subjects, (ii) provide at least the same level of protection as is required by the Privacy Shield Principles and notify us if it makes a determination that it cannot do so; and (iii) cease processing of the personal data or take other reasonable and appropriate steps to remediate if it makes such a determination. If BMI Telecom has knowledge that a third party acting as a controller is processing personal data covered by the Privacy Shield Framework in a way that is contrary to the Privacy Shield Principles, BMI Telecom will take reasonable steps to prevent or stop such processing.

With respect to our agents, we will transfer only the personal data covered by this Privacy Shield Policy needed for an agent to deliver to BMI Telecom the requested product or service. Furthermore, we will (i) permit the agent to process such personal data only for limited and specified purposes; (ii) require the agent to provide at least the same level of privacy protection as is required by the Privacy Shield Principles; (iii) take reasonable and appropriate steps to ensure that the agent effectively processes the personal data transferred in a manner consistent with BMI Telecom’s obligations under the Privacy Shield Principles; and (iv) require the agent to notify BMI Telecom if it makes a determination that it can no longer meet its obligation to provide the same level of protection as is required by the Privacy Shield Principles. Upon receiving notice from an agent that it can no longer meet its obligation to provide the same level of protection as is required by the Privacy Shield Principles, we will take reasonable and appropriate steps to stop and remediate unauthorized processing.

BMI Telecom remains liable under the Privacy Shield Principles if an agent processes personal data covered by this Privacy Shield Policy in a manner inconsistent with the Principles, except where BMI Telecom is not responsible for the event giving rise to the damage.

Privacy Policy Changes

BMI Telecom reserves the right to change, modify, add, or remove portions of this Policy at any time and without prior notice, and any changes will become effective immediately upon being posted unless we advise you otherwise. However, we will not use your Personal Information or Customer Data in a way that is materially different than the uses described in this Policy without giving you an opportunity to opt out of such differing uses. Your continued use of the Platform or Services after this Policy has been amended shall be deemed to be your continued acceptance of the terms and conditions of the Policy, as amended. We encourage you to bookmark this Web page and review this Policy regularly.

Contacting BMI Telecom

Our goal is to respect your privacy. If you have any questions, comments or concerns about our Privacy Policy, you may contact us by email at support@recorn.app attn: Privacy Officer or by mail to :

BMI Telecom, SIA.

Attn: Privacy Officer

21 Skolas,

Riga, Latvia

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